January 21, 2025 | Policy Brief

New U.S. Export Controls Seek to Prevent China From Weaponizing Biotech  

January 21, 2025 | Policy Brief

New U.S. Export Controls Seek to Prevent China From Weaponizing Biotech  

The United States wants to prevent China from acquiring commercial biotechnologies that could boost its military power, not just its economic growth. The U.S. Department of Commerce released an interim final rule on January 15 containing a series of new export controls targeting China’s access to critical components for its biotechnology sector. The rule was finalized the following day when published in the Federal Register.  

Under Secretary of Commerce for Industry and Security Alan F. Estevez said that the controls are designed to “focus on countries of concern while preserving the global community’s ability to responsibly use these laboratory instruments to advance the significant beneficial uses of biotechnology.” 

Export Controls Cover Technology Used to Train AI Systems  

The new export controls limit access to tools that the commercial life sciences sector uses to analyze proteins and develop novel pharmaceuticals, specifically industrial-grade high-parameter flow cytometers and liquid chromatography mass spectrometers. These technologies are critical for producing high-quality data used to train artificial intelligence (AI) systems that design biological products, potentially including biological weapons.  

The regulations also establish a series of tiered export licenses that place no limits on purchases by U.S. allies and partners but introduce a stringent review process for purchases by China and Russia, along with countries covered by a U.S. arms embargo or deemed state sponsors of terrorism. To prevent the diversion of this equipment or its components, the rules ban its reexport, as well as banning initial sales to countries that pose a diversion risk.  

A Tool for ‘Military Struggle’: PLA Embedded in Biotechnology Sector  

Chinese biotechnology firms have received billions of dollars in subsidies to develop cutting-edge technologies and products for both domestic and global markets. Their output includes novel medications, advanced medical procedures, and simulations of complex biological systems.  

To ensure that such accomplishments translate into military gains, the People’s Liberation Army (PLA) is deeply embedded within China’s biotechnology sector. In particular, the PLA boasts extensive ties to leading civilian firms such as BGI and MGI Tech, allowing the military to access their research and technology. Moreover, the PLA has signaled its interest in weaponizing the country’s biotechnology sector, with China’s leading military textbook identifying biology as a domain of “military struggle” and discussing an interest in using biological tools to enhance soldiers’ performance.  

Washington Should Act Rapidly to Prevent China From Integrating Biotechnology Breakthroughs Into Its Military 

The Trump administration should use the new export controls as a springboard for additional action. It should direct the National Security Council and Department of Commerce to monitor Chinese involvement in the U.S. biotechnology sector and ensure that the Department of Defense integrates biotechnology threats into its National Defense Strategy and Defense Planning Guidance.  

Moreover, the new Congress has an opportunity to foster coordination with U.S. allies and partners, for example by establishing an International Biotechnology Security Forum to counter the dual-use nature of China’s biotechnology sector. Lawmakers could also stand up a dedicated Congressional Biotech and National Security Task Force to monitor the government’s progress in this critical endeavor. 

Jack Burnham is a research analyst in the China Program at the Foundation for Defense of Democracies (FDD). Johanna (Jo) Yang is a research and editorial associate at Center on Cyber and Technology Innovation (CCTI) at FDD, where she works on issues related to related to nation-state cyber threats, critical infrastructure protection, and U.S. cybersecurity policy. For more analysis from Jack, Johanna, and FDD, please subscribeHERE. Follow Jack on X@JackBurnham802. Follow FDD on X@FDD. FDD is a Washington, DC-based, nonpartisan research institute focusing on national security and foreign policy. 

Issues:

Issues:

China Cyber Military and Political Power U.S. Defense Policy and Strategy

Topics:

Topics:

Russia Washington China United States Congress Chinese United States Department of Defense United States National Security Council People's Liberation Army United States Department of Commerce National Defense Strategy Jack Burnham